Privacy Policy

This Privacy Policy sets forth the principles and rules of data processing related to the W4 Labs Service (“Service”) and https://w4labs.io/ website (“Website”) and aims to provide the users with information about processing of their data while using the Service and the Website.

1. Summary

The Service is provided and the Website is operated by the company W4 Labs https://w4labs.io/: (”W4 Labs”, “we”, “us”, or “our”) that is responsible for the compliance of related data processing. In the terms of various regulations we are referred to as the controller. We might collect and process your data including personally identifiable information on various occasions and typically while using the Website or while using the Service. The data is processed for the following purposes:

  • Website analytics,
  • Maintaining customer relationships and subscriptions,
  • Providing the Service to customers,
  • Distributing user developed plug-ins,
  • Personalized advertising,
  • Providing customer support,
  • Maintaining security and uninterrupted operation of the Service, Marketing communication
  • Other communication,
  • Legal compliance,
  • Protecting of business interests, processing of claims and complaints.

The data is processed either on the basis of contractual relationships between us and our customers, users consent, legal obligations and legitimate interests. The purposes of the processing and the legal basis are set out in detail in the text following this summary. The Service is a custom AI layer integrated into messaging apps and other interface apps and services. In order to provide the service properly, we need to share data between the messaging app or other supported interface, our service and the AI provider. We aim to share as little data as possible with third parties for the operation of the Service. We do not share any data relating to our customer relationships, but the content of the messages must be passed between the interface service, our servers and AI provider. Some features might require us to use other third-party service in addition to interface service and AI service. For your protection, we anonymize the data, but we do not alter or modify the messages in any other way, so any information users include in the messages will be forwarded to AI provider and possibly other third-party services that are required to provide the Service. We recommend that you do not disclose any sensitive information and ask that you do not disclose any personally identifiable information about others. Data subjects have the following rights in connection with processing of their personal data:
(1) the right of access to personal data,
(2) the right to rectification of inaccurate personal data,
(3) the right to restriction of processing,
(4) the right to erasure of personal data,
(5) the right to object to processing of personal data based upon legitimate interest,
(6) the right to revoke consent,
(7) the right to data portability and
(8) the right to lodge a complaint with a supervisory authority if they are from EEA.

2. Purposes of Processing in Detail

2.1 Website Analytics

The Website uses website analytics service for gathering aggregated statistical data about usage of the Website. We use this data to improve the Website and your user experience, to improve the reach of the services and to measure effectiveness of our advertisement. We might collect information necessary to discern unique website visits or referral sources and data relating to interactions with the website. We collect and process the data based on our legitimate interest to improve quality of our service and user experience, identify issues with the Website and manage our marketing strategy. Usage of cookies and similar technologies is subject to consent from the user.

2.2 Maintaining Customer Relationships and Subscriptions

We collect information about our customers in order to manage customer relationships and to enable customers to use the Service. Data such as name, address, telephone number, email address, details of the level of service, subscription chosen, payments made and due are collected and processed. The processing is necessary to enter into the contract between us and the customer and to maintain the customer relationship. We do not collect and process information about the payment methods used (e.g., credit card information); this information is collected and processed by our payment service provider and is not shared with us. The data collected may be archived for the duration of the contract and for 3 years after the expiry of the contract.

2.3 Providing the Service to Customers

The Service takes input from the user in form of a message and then uses the AI service to generate the proper response sending it back to the customer. To operate properly the Service needs to collect and process the message, context, customers telephone number and other technical data. The Service relies upon data exchange between the customers chosen interface and AI model and the message and answer may be disclosed to the providers of those services. Several messages and answers are kept for a short time on our servers for context of the interaction and to provide better interactive experience. The data is collected and processed on the basis of the underlying contract for provision of the Service, however the user has to opt-in for communication through the messaging app or similar interface. The Service cannot be provided unless the user provides opt-in for the communication.

2.4 Distribution of user developed plug-ins

If you develop a plug-in and choose to make it available to other users through the Plug-in Store in accordance with the Terms of Service, you will be required to provide certain information and documentation to facilitate distribution of the plug-in through the Plug-in Store. We will post this information and documentation on the Plug-in Store and make it available to the public. We may also collect and process information relating to the revenue generated by the plug-in and our royalties. The processing is necessary to perform the contract in accordance with the Terms of Service.

2.5 Advertising and personalization

The WIf you opt-in to our personalized advertising program, we may provide you with advertisements tailored to your interests. In order to target ads effectively, we may collect and process information about how you interact with the Service, including your inputs and outputs and your customer information, and create your profile. This profile may be used to provide you with more relevant advertising. This processing is optional and is based on your freely given consent.ebsite uses website analytics service for gathering aggregated statistical data about usage of the Website. We use this data to improve the Website and your user experience, to improve the reach of the services and to measure effectiveness of our advertisement. We might collect information necessary to discern unique website visits or referral sources and data relating to interactions with the website. We collect and process the data based on our legitimate interest to improve quality of our service and user experience, identify issues with the Website and manage our marketing strategy. Usage of cookies and similar technologies is subject to consent from the user.

2.6 Providing Customer Support

We provide customer support services accessible via channels provided on the product website. In order to process customer support requests, we need to collect information about the subject of the request, a detailed description of the problem, the priority, any documents relevant to the request (attachments such as screenshots, website links, etc.), contact information and any other information provided by the customer. Data required to process customer support requests is processed on the basis of a legitimate interest in resolving any issues that the customer may have while using the Service. The data is kept until the support request has been resolved and for 6 months thereafter, and if it relates to a contract, for the duration of that contract and for 1 year after the termination of that contract.

2.7 Maintaining Security and Uninterrupted Operation of the Service

We care about the security of the Service and its users, and about providing the Service properly and without interruption. To achieve this, we need to collect technical data about the use of the Service and interactions with the infrastructure in the form of logs. This processing is carried out in accordance with the legitimate interest in the secure and proper provision of the Service. The data will be archived for several days.

2.8 Marketing Communication

The Website uses website analytics service for gathering aggregated statistical data about usage of the Website. We use this data to From time to time, we may send email or messages to customers about the latest news, new products and services, changes to the Service and other relevant information about us and our business. The customer's email address or other contact will be added to the mailing list unless the customer opts out of receiving marketing communications. If the user provides us with a specific consent to contact them with other marketing communication, we might use their contact information to advertise third-party products. On the basis of our legitimate interest in expanding our business and to inform the customers about our business, the email address will be kept on the mailing list until the customer unsubscribes or the associated customer account is closed. The option to unsubscribe will be offered in the account settings and in each message. If the user provided special consent with additional marketing communication, they can withdraw such consent anytime.improve the Website and your user experience, to improve the reach of the services and to measure effectiveness of our advertisement. We might collect information necessary to discern unique website visits or referral sources and data relating to interactions with the website. We collect and process the data based on our legitimate interest to improve quality of our service and user experience, identify issues with the Website and manage our marketing strategy. Usage of cookies and similar technologies is subject to consent from the user.

2.9 Other Communication

If someone contacts us using the contact details we publish, we will contact them to respond to their request. In order to do this, we usually process contact details (email, address or telephone), first name, surname and the content of the communication. The communication is based on their consent implied by contacting us. The data will only be kept for a reasonable period of time to process and consider the communication and in any case no longer than 1 year after the communication has ended.

2.10 Legal Compliance

The WebsAs a company, we have certain legal obligations to collect, process and archive certain data, such as data about our customer relationships, invoices, payments, claims, etc., for the purposes of keeping company accounts and other legal obligations. Data collected for these purposes may be retained for the relevant legal retention periods, which can be up to 10 years and under certain conditions even longer.ite uses website analytics service for gathering aggregated statistical data about usage of the Website. We use this data to improve the Website and your user experience, to improve the reach of the services and to measure effectiveness of our advertisement. We might collect information necessary to discern unique website visits or referral sources and data relating to interactions with the website. We collect and process the data based on our legitimate interest to improve quality of our service and user experience, identify issues with the Website and manage our marketing strategy. Usage of cookies and similar technologies is subject to consent from the user.

2.11 Protection of Business Interests, Processing of Claims and Complaints

Any data collected and processed by us may be used to protect us from claims, to enforce our claims and to resolve disputes and complaints. Processing for this purpose is based on the legitimate interest in protecting our business interests, enforcing our claims and defending ourselves against claims by third parties and settling disputes and complaints. The data may be archived even after the above retention periods have expired if there is an ongoing dispute or a reasonable risk of a dispute. The data will be archived until the dispute is resolved or, in some cases, for the duration of the statute of limitations.

3. Transfers of Data

We keep all data collected secure and confidential. We will never sell your information to third parties without your explicit consent. However, data may be disclosed to third parties where we are required to do so by law and where we use third party services to outsource some of the processing. We select processors with due care and require them to protect the data under data processing contracts. Where we share data with service providers outside of EEA or USA we ensure that privacy and protection of the shared data is ensured in accordance with applicable legislation.Be aware that if you knowingly misrepresent information in your request, you may be held liable for damages under DMCA.

In general, we employ the following categories of processors:Be aware that if you knowingly misrepresent information in your request, you may be held liable for damages under DMCA.

  • accounting, tax and legal advisers;
  • IT infrastructure services (cloud computing, webhosting, e-maiCustomBulletPointng service etc.);
  • payment service providers;
  • interface services,
  • AI service providers,
  • feature enabCustomBulletPointng third-party services,
  • third-party plugin service providers,
  • web analytics services;    
  • customer service;
  • contractors (e.g., customer support operators).

3.1 Interface Services

The Service uses instant messaging applications or other interface for accessing the Service. Therefore, in order to access the Service, data must be exchanged between the interface service provider and our servers. We do not have access to a user's contacts or other messages not addressed to our Service unless they provide us with specific permission. Use of the instant messaging service or other third-party interface service is subject to the third-party provider's terms and conditions and privacy policy. The User must maintain access to the Instant Messaging Service or other interface service in order to properly use the Service.

3.2 AI Services

The Service uses third-party AI models to process messages and generate appropriate responses. Therefore, we must disclose the content of the message to the AI service provider. We use end-to-end encryption and anonymize the messages to protect your privacy. However, anything you include in the message itself will be disclosed. You are in complete control of the content of the message and we advise you not to disclose sensitive information and we require you not to disclose personal information about third parties.

3.3 Feature Enabling Third-party Services

Certain features require the use of additional third-party services and we may need to share some information with these providers to ensure the proper provision of services (e.g., voice transcription, translations, etc.). We will share as little information as possible with such providers and, where appropriate, we will anonymize such information or use pseudonyms.

3.4 Third-party Plugins

The Service allows third parties to create plugins to enhance and extend the functionality of the Service. Use of such plugins may require us to share data with the operator of such plugin, or the plugin itself may collect additional data. Use of plugins is optional and may be subject to additional third-party terms and conditions, privacy policies and may require account registration with or payments to third parties. The user is in control of which plugins they use and if they choose to use a plugin, we will interpret that action as consent to share the necessary data with the provider. We recommend that the user checks the plugin provider's website for relevant information about the plugin and the data it collects and processes.

4. Cookies

4.1 What are Cookies in General

Cookies are small text files stored on your browser. They are used by web developers to help users navigate their websites efficiently and perform certain functions. Because of their central role in improving or enabling usability or website processes, disabling cookies may prevent users from using certain features of the website. To learn more about cookies, visit https://allaboutcookies.org/, or the related Wikipedia page.

4.2 Cookies used by the Website

The Website uses certain cookies that are necessary for the proper operation of the Website and to ensure its security and the safety of its users. For example, cookies are used to handle login to the user account and to store session information. The storage of such cookies is necessary to provide the service, and therefore does not require the user's consent to be stored on the user's device. In addition to technical cookies, we might use technologies to collect data relating to our advertisement and website usage using cookies or similar technologies. In that case we collect user consent with storing and using cookies or similar technologies.

4.3 Choices of the User about Cookies

The user can set their browser to reject all cookies or only the ones they choose. Generally, information on how to set the cookie preferences of the browser can be found in the help section of the browser. If the user chooses to reject all cookies, the user should be aware that the Website may not function properly.The user can also delete all cookies from their browser after visiting the website in order to maximize their privacy.

5. Third-party Integrations Using W4 Labs Service

Where a third party integrates its product with the Service, we collect and process data on behalf of that third party as a processor under a data processing contract subject to the relevant legislation. In this case, we will only process data for a limited range of purposes permitted under the contract, which will generally include:

  • Provision of the Service,
  • Customer support,
  • Cooperation with the provider,
  • Legal compliance,
  • Protection of Business Interests, Processing of Claims and Complaints.
  • contractors (e.g., customer support operators).

End-user can refer to section 2 for more detail with the specifics described below.

5.1 Provision of Service for Third-party Integration

While providing the Service for third-party integration we are generally not in direct contact with the end user, but the third-party service generally acts as an interface to the Service, aggregating the end user's messages. Otherwise, the information about how the data is processed to provide the services to our end users applies, including the information about disclosing the data to third parties. These third parties act as our sub-processors.

5.2 Customer Support

While providing the Service for third-party integration we generally do not handle end user issues directly, but end user issues may be forwarded to us for resolution or our staff may otherwise assist in resolving end user issues.

5.3 Cooperation with the Provider

While we work with the provider to deliver the service to the end user, we may process end user data on an ad hoc basis as necessary. In such cases, we will endeavor to keep the data processing to a minimum and archive the data only where necessary.

5.4 Responsibilities of the Third-party Service Provider

When we act as a processor, we provide the service to the third-party service provider as our customer. This means that the third-party service provider acts as the controller of any processing of personal data and is solely responsible for informing end users about the processing and obtaining any necessary consents.

6. Automated Processing

The processing of data required for the establishment of the contract for the provision of the Service and the operation of the Service is carried out entirely by automated means. If you are denied registration or access to the Service by these automated means, please contact us at the provided contacts and we will ensure that our staff or associates review the case manually and notify you of the outcome.

7. Children

The Service is not available to children under the age of thirteen (16). Minors between the ages of thirteen (16) and eighteen (18) must have the permission and consent of a parent or legal guardian to use the Service.

8. Advice on Rights

We may need to verify the identity of the user when they make a request to exercise any of their rights and is entitled to request further information in order to comply with their request.

8.1 Right of Access

In relation to the processing of personal data, the data subject has the right to obtain, upon request, information about the processing and a copy of the data processed about them.

8.2 Right to Rectification

If the data subject has reason to believe that their personal data is inaccurate, out of date or incorrect in any way, they have the right to contact us and we will ensure due rectification when accurate, up to date and correct information is provided.

8.3 Right to Restriction of Processing

If the processed personal data are inaccurate or if the data subject has objected to the processing, the data subject has the right to request that the processing of the personal data be restricted.For the duration of the restriction, the personal data shall only be stored and shall not be subject to any other operation without the consent of the data subject. The restriction of processing will last for the time necessary to resolve the situation. The data subject shall be informed of the termination of such restriction.

8.4 Right to Erasure (Right to be Forgotten)

In cases where the data subject withdraws consent or the personal data is no longer necessary, the data subject has the right to have the data erased.However, in some cases, the right to erasure is limited.
For example, personal data processed to comply with legal obligations imposed on us may not be erased before the end of the legal retention period.

8.5 Right to Object to Processing

In the case of processing based on legitimate interests and/or for the purposes of direct marketing, the data subject may lodge a reasoned objection to the processing. The grounds for the objection shall be assessed and the decision shall be notified to the data subject. On the basis of the assessment, the processing will either cease or the objection will be rejected.

8.6 Right to Withdraw Consent to Processing

Where personal data is processed on the basis of consent, such consent may be withdrawn at any time.

8.7 Right to Data Portability

Where the processing of personal data provided by the data subject is based on consent or on a contract and is carried out wholly by automated means and the personal data are stored in a structured machine-readable format, the data subject shall have the right to obtain their personal data in a structured machine-readable format.

8.8 Right to Lodge a Complaint with Supervisory Authority

If the data subject is from the EEA and has reason to believe that their personal data are not being processed in accordance with applicable regulations, they have the right to lodge a complaint with a supervisory authority in their country of habitual residence, place of work or the place where the alleged breach occurred.

9. California Users

If the user is from California and the California Consumer Protection Act applies than the following special terms apply to them.

End-user can refer to section 2 for more detail with the specifics described below.

9.1 Categories of Collected Personal Information and Purposes of Processing

Categories of collected personal information and purposes of processing are described in detail in Section 2 of this Privacy Policy.

9.2 Additional Rights

California users may exercise the following additional rights:

  • right to know - California users can request disclosure of:
    (1) the categories and/or specific pieces of personal information we have collected about them,
    (2) the categories of sources for that personal information,
    (3) the purposes for which we use that information,
    (4) the categories of third parties with whom we disclose the information, and
    (5) the categories of information that we sell or disclose to third parties. The request can be made up to twice a year, free of charge,
  • right to delete - California users can request we delete personal information we collected from them and tell our service providers to do the same, subject to certain exceptions (such as if we are legally required to keep the information),
  • right to opt-out of sale or sharing - California users may request that we stop selling or sharing their personal information, including via a user-enabled global privacy control. We cannot sell or share their personal information after we receive the opt-out request unless they later authorize us to do so again,
  • right to correct - California users may ask us to correct inaccurate information that we have about them,
  • right to limit use and disclosure of sensitive personal information- California users can direct us to only use their sensitive personal information (for example, social security number, financial account information, precise geolocation data, or genetic data) for limited purposes, such as providing them with the services they requested.

10. Final Provisions

10.1 Changes to the Privacy Policy

We reserve the right to change this Privacy Policy as the Website and the Service or business needs evolve. We will publish any changes to this Privacy Policy on the Website and notify registered customers of changes to this Privacy Policy by email at least one month before the changes take effect.

10.2 Contact Details

If you have any questions about privacy and personal data processing or you wish to exercise your rights, please contact us at privacy@oso.ai

10.3 Effective Date

This Privacy Policy shall be effective from September 1, 2023

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